ATTIS FITNESS PRIVACY POLICY

Last updated 15/06/2020

Consent to installation of the App

Under data protection laws, we are required to provide you with certain information about who we are, how we process your personal data and for what purposes, and your rights in relation to your personal data. Please also read our Terms and Conditions of Service which sets out the terms governing the Services ("Terms").

Before installation of this App, please indicate your consent to our processing of your personal data (including your name, contact details, financial and device information) as described in the policy.

YES I consent to the installation of the App for the purposes of tracking my location, activity data and analysing my running gait.

NO I do not consent to the installation of the App.

How you can withdraw consent

Once you provide consent by selecting "YES", you may change your mind and withdraw consent at any time by contacting us at info@attisfitness.co.uk but that will not affect the lawfulness of any processing carried out before you withdraw your consent.

Consent to processing Location Data

YES I consent to processing of my Location Data (including details of my current location disclosed by GPS technology so that location-enabled Services are activated to provide Attis’ core Services, including the Stridesense app.

NO I do not consent to processing of my Location Data and location-enabled Services are disabled in my settings.

Location Data

Attis Fitness Limited (we) are committed to protecting your personal data and respecting your privacy.

Introduction

This policy (together with the Terms) applies to your use of:

• Attis Fitness mobile application software Stridesense available on android and IOs (App) or hosted on www.attisfitness.co.uk (App Site), once you have downloaded a copy of the App onto your mobile telephone or handheld device (Device).

• Any of the services accessible through the App (Services) that are available on the App Site or other sites of ours (Services Sites). This policy sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed by us. Please read the following carefully to understand our practices regarding your personal data and how we will treat it.

This policy is provided in a layered format so you can click through to the specific areas set out below.


[IMPORTANT INFORMATION AND WHO WE ARE]

[THE DATA WE COLLECT ABOUT YOU]

[HOW IS YOUR PERSONAL DATA COLLECTED?]

[HOW WE USE YOUR PERSONAL DATA]

[DISCLOSURES OF YOUR PERSONAL DATA]

[INTERNATIONAL TRANSFERS]

[DATA SECURITY]

[DATA RETENTION]

[YOUR LEGAL RIGHTS]

[GLOSSARY]

[DESCRIPTION OF CATEGORIES OF PERSONAL DATA]


1. Important information and who we are

Attis Fitness Limited is the controller and is responsible for your personal data (collectively referred to as "Company", "we", "us" or "our" in this policy).

Contact details

If you have any questions about this privacy policy or our privacy practices, please contact us by writing to us at info@attisfitness.co.uk or Attis Fitness, Scion House, Stirling University Innovation Park, Stirling, United Kingdom, FK9 4NF.

You have the right to make a complaint at any time to the Information Commissioner's Office (ICO), the UK supervisory authority for data protection issues or other competent supervisory authority of an EU member state if the App is downloaded outside the UK.

Changes to the privacy policy and your duty to inform us of changes

We keep our privacy policy under regular review.

This version was last updated on 15/06/2021. It may change and if it does, these changes will be posted on this page and, where appropriate, notified to you [by SMS OR by email OR when you next start the App or log onto one of the Services Sites]. The new policy may be displayed on-screen and you may be required to read and accept the changes to continue your use of the App or the Services.

It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during our relationship with you.

Third party links

Our Sites may, from time to time, contain links to and from the websites of our partner networks, advertisers and affiliates. Please note that these websites and any services that may be accessible through them have their own privacy policies and that we do not accept any responsibility or liability for these policies or for any personal data that may be collected through these websites or services, such as Contact and Location Data. Please check these policies before you submit any personal data to these websites or use these services.

2. The data we collect about you

We may collect, use, store and transfer different kinds of personal data about you as follows:

We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data could be derived from your personal data but is not considered personal data in law as this data will not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific App feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy policy.

We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data).

How is your personal data collected?

We will collect and process the following data about you:

Cookies

We use cookies [and/or other tracking technologies] to distinguish you from other users of the App, App Site, the distribution platform (Appstore) or Services Sites and to remember your preferences. This helps us to provide you with a good experience when you use the App or browse any of Our Sites and also allows us to improve the App and Our Sites. For detailed information on the cookies we use, the purposes for which we use them and how you can exercise your choices regarding our use of your cookies, see our cookie policy. If you do not want information collected through the use of these technologies, there is a simple procedure in most browsers that allows you to automatically decline many of these technologies, or to manage them.

3. How we use your personal data

We will only use your personal data when the law allows us to do so. Most commonly we will use your personal data in the following circumstances:

We will only send you direct marketing communications by email or text if we have your consent. You have the right to withdraw that consent at any time by contacting us.

We will get your express opt-in consent before we share your personal data with any third party for marketing purposes.

Purposes for which we will use your personal data

Purpose/activity Type of data Lawful basis for processing
To install the App and register you as a new App user

(a) Identity

(b) Contact

(c) Financial

(d) Device

(a) Your consent
To process your email address and your password

(a) Personal

(b) Contact

(a) Necessary for our legitimate interests in protecting the security of your account.

(b) Performance of contract with you (i.e. sending you important information about Attis Fitness, the App, our product or changes to this policy and/or any other terms and conditions

To process your Activity Data so that you can analyse it and develop or improve features and Services

(a) Location

(b) Steps

(c) Activity Time

(d) Frequency of Activities

(e) Distance

(f) Movement/running gait

(a) Your consent

(b) Performance of a contract with you

To process in-App purchases and deliver Services including managing payments and collecting money owed to us

(a) Identity

(b) Contact

(c) Financial

(d) Transaction

(e) Device

(f) Marketing and Communications

(g) Location

(a) Your consent

(b) Performance of a contract with you

(c) Necessary for our legitimate interests (to recover debts due to us)

To manage our relationship with you including notifying you of changes to the App or any Services

(a) Identity

(b) Contact

(c) Financial

(d) Profile

(e) Marketing and Communications

(a) Your consent

(b) Performance of a contract with you

(c) Necessary for our legitimate interests (to keep records updated and to analyse how customers use our products/ Services)

(d) Necessary to comply with legal obligations (to inform you of any changes to our terms and conditions)

To enable you to participate in a prize draw, competition or complete a survey

(a) Identity

(b) Contact

(c) Device

(d) Profile

(e) Marketing and Communications

(a) Your consent

(b) Performance of a contract with you

(c) Necessary for our legitimate interests (to analyse how customers use our products/Services and to develop them and grow our business)

To administer and protect our business and this App including troubleshooting, data analysis and system testing

(a) Identity

(b) Contact

(c) Device

Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security)

(a) To deliver content and advertisements to you

(b) To make recommendations to you about goods or services which may interest you

(c) To measure and analyse the effectiveness of the advertising we serve you

(d) To monitor trends so we can improve the App

(a) Identity

(b) Contact

(c) Device

(d) Content

(e) Profile

(f) Usage

(g) Marketing and Communications

(h) Location

(a) Consent

(b) Necessary for our legitimate interests (to develop our products/Services and grow our business)


4. Disclosures of your personal data

Consent

When you consent to providing us with your personal data, we will also ask you for your consent to share your personal data with the third parties set out below for the purposes set out in the table Purposes for which we will use your personal data above:


Other Attis users:

Your activities and activity data associated with your Attis account are set to "Private" by default. You may decide to allow others to view your activities and activity data by changing the privacy settings in your Activity account.


Third-party app, platform or service providers with whom you ask Attis to share your data:

If you choose to authorize Garmin to permit a third party, such as your wellness program provider, or an app, such as MyFitnessPal, Strava, or TrainingPeaks, to access your activity data in your Garmin account, then we will share such data with the third party. We will not do this without your explicit consent. Once you direct us to share data with a third party, the third party’s handling of your personal data is the responsibility of that third party and you should carefully review the third party’s privacy policy. You can choose to stop sharing data with the third-party app, platform or service provider at any time within your Attis account.


Other disclosures

We may disclose personal data about you to others: (a) if we have your valid consent to do so; (b) to comply with a valid legal order, court order, legal process, or other legal obligation; (c) to enforce any of our terms and conditions or policies; or (d) as necessary to pursue available legal remedies or defend legal claims.

We may also transfer your personal data to an affiliate, a subsidiary or a third party in the event of any reorganisation, merger, sale, joint venture, assignment, transfer or other disposition of all or any portion of Attis’s business, assets or shares, including, without limitation, in connection with any bankruptcy or similar proceeding, provided that any such entity that we transfer personal data to will not be permitted to process your personal data other than as described in this Privacy Policy without providing you notice and, if required by applicable laws, obtaining your consent.


5. International transfers

At this stage , we will not transfer your personal data outside the European Economic Area (EEA). However, this may change as we expand internationally.

6. Data security

All information you provide to us is stored on our secure servers in the EEA. Any payment transactions [carried out by us or our chosen third-party provider of payment processing services] will be encrypted using [Secured Sockets Layer technology. Where we have given you (or where you have chosen) a password that enables you to access certain parts of Our Sites, you are responsible for keeping this password confidential. We ask you not to share a password with anyone.

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed.

We will collect and store personal data on your Device using application data caches and browser web storage (including HTML5) and other technology.

Certain Services include social networking, chat room or forum features. Ensure when using these features that you do not submit any personal data that you do not want to be seen, collected or used by other users.

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator when we are legally required to do so.

7. Data retention

Details of retention periods for different aspects of your personal data are available in our retention policy which you can request by contacting us.

By law we have to keep basic information about our customers (including Contact, Identity, Financial and Transaction Data) for six years after they cease being customers for tax purposes.

In some circumstances you can ask us to delete your data: see [Your legal rights] below for further information.

In some circumstances we will anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.

In the event that you do not use the App for a period of [TIME PERIOD] then we will treat the account as expired and your personal data may be deleted.

8. Your legal rights

Under certain circumstances you have the following rights under data protection laws in relation to your personal data. You have the right to:

Request access to your personal data (commonly known as a "data subject access request"). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.

Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.

Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.

Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.

Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios:

Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.

Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.

You also have the right to ask us not to continue to process your personal data for marketing purposes.

You can exercise any of these rights at any time by contacting us.

Glossary

LAWFUL BASIS

Consent means processing your personal data where you have signified your agreement by a statement or clear opt-in to processing for a specific purpose. Consent will only be valid if it is a freely given, specific, informed and unambiguous indication of what you want. You can withdraw your consent at any time by contacting us.

Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.

Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.

Comply with a legal obligation means processing your personal data where it is necessary for compliance with a legal obligation that we are subject to.

THIRD PARTIES

Internal third parties

Other companies in the Attis Fitness Limited Group (if any).

External third parties

Here are some examples of third party service providers we currently use: